OFFICE OF THE SECRETARY
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
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OFFICEOFTHESECRE'IAHY
POSTAL RATE AND FEE CHANGES, 2000
:
Docket No. R2000-1
AMERICAN BANKERS ASSOCIATION AND
NATIONAL ASSOCIATION OF PRESORT MAILERS
JOINT INTERROGATORIES
TO E-STAMP WITNESS JONES
(ABA&NAPM/E-STAMP-Tl-1-6)
(June 19,200O)
Pursuant to Sections 25 and 26 of the Rules of Practice of the Postal Rate Commission,
the American Bankers Association and the National Association of Presort Mailers hereby
submit these joint interrogatories and requests for production of documents.
If the witness to
whom an interrogatory is directed is unable to answer the interrogatory or produce the
requested documents and another person is able to do so, the interrogatory or request should
be referred to such person,
If data requested are not available in the exact format or level of detail requested, any
data available in (1) substantially similar format or level of detail or (2) susceptible to being
converted to the requested format and detail should be provided.
Responses to requests for explanations or the derivation of numbers should be
accompanied by workpapers.
The terms “workpapers” shall include all backup material
whether prepared manually, mechanically or electronically, and without consideration to the
type of paper used. Such workpapers should, if necessary, be prepared as part of the witness’s
responses and should “show what the numbers were, what numbers were added to other
numbers to achieve a final result.” The witness should “prepare sufficient workpapers so that it
is possible for a third party to understand how he took data from a primary source and
developed that data to achieve his final results.” Docket No. R83-1, Tr. 1O/2795-96.
ABA&NAPM I E-Stamp-T1 -1. Please confirm that IBI First Class Letter Mail (“FCLM”) will be
delivered to the USPS collection system as single piece mail, and will not be presented
to the USPS in trays, banded and sleeved.
ABA&NAPM/ E-Stamp-Tl-2.
If the Postal Service, not the “shipper,” will have to tray, sleeve,
label and strap the trays with mail prepared with PC Postage, how is this more efficient for the
Postal Service than when it is able to merely cross dock trays that are sleeved, labeled, and
strapped when they arrive at the BMEU, ( and not just any postal facility)?
ABA&NAPM/ E-Stamp-Tl-3.
Do you agree that mail prepared with PC Postage will have to be
culled and segregated from other collection box mail on an USPS AFCS and then sorted at
least once, and probably twice, to achieve the same level of sortation as automation mail which
qualifies for the basic automation FCLM rate? If you do not agree, state each reason you have
for disagreeing.
ABA&NAPM/ E-Stamp-T14
Please refer to the statement in your testimony at Page 8, Line 16
where you state, “Inspections are not necessary because the software has insured
compliance.”
a.
Are you aware of any instances in the past five years where individuals have
tampered with ANY type of software program and caused problems with the
accuracy or security of such programs?
b.
Why would it not be necessary for the USPS to inspect all IBI FCLM to assure
that the postage has not been underpaid (e.g., mail weighing more than one ounce
with insufficient postage)? Please explain if you believe it is not necessary for the
USPS to make an inspection of IBI FCLM for such purpose.
C.
Please explain why it would not be necessary for USPS to inspect IBI FCLM to
assure that the indicia is legible.
d.
Please explain why it would not be necessary for USPS to inspect IBI FCLM to
assure that such mail is of the proper size, shape and dimension, particularly
where the IBI indicia may have been placed on a label which has been placed on
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the mail.
e.
Please explain why the USPS would not have to inspect IBI FCLM to assure that
the indicia is not counterfeit and that it has been printed from an authorized
software package which will result in appropriate compensation to the USPS for
such mail.
ABA&NAPM/ E-Stamp-T1 -5. Please refer to the “address cleansing” features of the PC Open
System which you discuss at Page 9, Line 14 and Page 10, Line 6 of your testimony.
Will customers using your clients Open PC Postage Product be required to check the
accuracy of the mail piece address against a current address-matching
list every six
months? Will this address updating process be the same as required for mail receiving
worksharing discounts? Please explain your answer.”
ABA&NAPM/E-Stamp-Tl-6.
Please refer to Page 9, Line 11 of your testimony where you state
that “For all of the discounted postage products the customers only have to perform this
address cleansing on a voluntary basis
.” Please reconcile this statement with the
fact that automated FCLM must comply with move update requirements.
Respectfully submitted,
AMERICAN BANKERS ASSOCIATION
NATIONAL ASSOCIATION OF PRESORT MAILERS
Henry A. Hart, Esq.
Reed Smith Shaw & McClay LLP
1301 K Street N.W.
Suite 1100 - East Tower
Washington, DC 20005
Ph: 202-414-9225
Fax:202-414-9299
Counsel for
National Association
of Presort Mailers
American Bankers Association
1120 Connecticut Ave., NW
Washington, DC 20036
Ph: 202-663-5035
Fax:202-828-4548
Counsel for
American Banker Association
Date: June 19, 2000
Washington, D.C.
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CERTIFICATE OF SERVICF
I hereby certify that I have this date served the instant document on all participants of
record in this proceeding in accordance with Section 12 of the Rules of Practice.
June 19, 2000